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China Privacy Law PIPL deadlines and compliance calendar

Use this calendar to separate effective dates from annual, event-driven, filing, retention, and renewal deadlines under China's personal-information rules.

For current operations, the main dates are triggered by personal-information volume, cross-border transfer route, contract effectiveness, assessment expiry, material changes, incidents, and processing of minors.

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Author
Sorena AI
Published
Jul 5, 2026
Updated
Oct 15, 2026
3 sections15 primary sources
Overview

PIPL has applied since 1 November 2021. A must be completed before the higher-impact processing listed in Article 55, and its report and processing record must be kept for at least three years. Other compliance dates depend on the activity: annual threshold counts restart on 1 January for data exports; some standard contracts must be filed within 10 working days; security-assessment results expire after three years; specified privacy-officer information must be reported within 30 working days; and compliance audits can recur annually, at least every two years, or, from 1 September 2026 for qualifying small processors, at least every five years.

Section 1

Dates when the main rules took effect

Each date marks when an instrument began to apply. Expired transition periods are historical and do not create a new grace period for current processing. A product launched now must satisfy the rules already in force before the relevant activity begins.

  • 1 May 2021: the provisions defining necessary personal information for 39 common App categories took effect. Covered Apps may not deny basic functions because a user refuses non-necessary personal information.
  • 1 November 2021: the Personal Information Protection Law (PIPL) took effect.
  • 1 August 2022: the current Mobile Internet Application Information Service Management Provisions took effect and replaced the 2016 provisions.
  • 1 September 2022: the Measures for Security Assessment of Data Export took effect. Their original two-year validity rule was superseded by the three-year rule in the 2024 cross-border provisions.
  • 1 June 2023: the Measures for the for Personal Information Export took effect. Their six-month remediation period for pre-existing exports ended in 2023.
  • 2023-2024 App filing transition: Apps already operating when the Ministry of Industry and Information Technology (MIIT) issued its July 2023 notice were assigned September 2023 through March 2024 to file. New Apps covered by the notice must file before operating; routine supervision has continued since July 2024.
  • 22 March 2024: the Provisions on Promoting and Regulating Cross-border Data Flow took effect on publication. They changed exemptions, annual thresholds, and assessment validity, and they control where earlier export measures are inconsistent.
  • 1 January 2025: the Network Data Security Management Regulations took effect, adding operational rules for network data processors and specific duties for processors handling large volumes of personal information.
  • 1 May 2025: the Personal Information Protection Compliance Audit Measures took effect.
  • 1 January 2026: the Personal Information Export Certification Measures took effect, providing the current certification framework for eligible cross-border transfers.
  • 1 September 2026: the Small Personal Information Processor Personal Information Protection Simplified Measures took effect. They define a small processor as one that processes the personal information of fewer than 100,000 people and establish simplified compliance measures, including a five-year audit interval.
Section 2

Recurring and fixed-date calendar

Assign each applicable item to a named owner. The threshold counts are counts of people, not records. The Cyberspace Administration of China's (CAC) April 2026 Q&A says the count excludes deleted personal information and that thresholds include the stated number.

  • Every 1 January: restart the calendar-year count of people whose personal information or sensitive personal information is provided abroad. For a processor that is not a critical information infrastructure operator (non-CIIO), exports of 100,000 to fewer than 1 million people, excluding sensitive personal information, or fewer than 10,000 people whose sensitive personal information is exported generally require a or certification unless an exemption applies. Exports reaching 1 million people or 10,000 people with sensitive personal information require a ; important data and CIIO exports have separate mandatory triggers.
  • At least once every two years: a processor handling personal information of 10 million or more people must conduct a personal information protection compliance audit. Until 1 September 2026, other processors remain subject to PIPL's requirement for periodic audits, but the binding measures do not set one universal interval for every smaller processor. From that date, a small processor handling personal information of fewer than 100,000 people may use the simplified audit method and must conduct an audit at least every five years; the annual audit rule for processors of minors' personal information still applies, and a small processor with valid personal information protection certification is exempt from that audit during the certificate's validity.
  • By the end of each January: a processor of minors' personal information must report the prior year's minors' personal-information compliance-audit status. The underlying Minors Online Protection Regulations require an annual audit; the December 2025 CAC notice specifies the reporting date.
  • Annually: a large online platform, as defined by the Network Data Security Management Regulations, must publish a personal information protection social responsibility report. The regulation requires annual publication but does not set one universal calendar date.
  • At least three years: retain every report and the associated processing record. The retention period runs from the relevant assessment and record, not from PIPL's effective date.
Section 3

Event-driven filing and review deadlines

These clocks start when a contract takes effect, a volume threshold is reached, reported information changes, an assessment nears expiry, or the facts of a transfer change. Do not wait for an annual review if one of these events occurs.

Does every China data export need a filing or security assessment?

No. First check whether the data contains personal information or important data, whether the exporter is a critical information infrastructure operator, whether an exemption applies, and how many people are counted from 1 January of the current year. Some transfers are exempt from the export mechanism, some fall into the standard-contract or certification band, and important-data, CIIO, or high-volume transfers require a . PIPL notice, separate-consent, impact-assessment, security, and recipient-protection duties can still apply even when the export mechanism is exempt.

Is a security-assessment result renewed automatically after three years?

No. A processor that needs to continue the transfer and has no reapplication trigger may apply for a three-year extension within the 60-working-day period before expiry. CAC approval is required. If the purpose, method, scope, data categories, overseas use, retention period, control, legal environment, or another material risk factor changes in a way covered by the rules, review the reapplication duty instead of relying on the extension process.

What should a team put on its PIPL calendar if no fixed date applies?

Use event-based reminders tied to the actual trigger: before higher-impact processing or a cross-border export starts; when a takes effect; when annual export counts approach a threshold; when privacy-officer information changes; before a security-assessment result expires; and when the transfer purpose, data, recipient, processing method, retention period, or legal environment changes. Keep the source, route decision, owner, approval, filing receipt, assessment, and next review date together.

  • : file the effective standard contract and the report with the provincial cyberspace administration within 10 working days after the contract takes effect. Complete the assessment and contract before the export begins.
  • change: redo the assessment, supplement or replace the contract, and complete the corresponding filing when the export purpose, scope, categories, sensitivity, method, storage location or overseas retention period changes, when the overseas recipient's use or method changes, or when another change may affect individual rights.
  • Security-assessment intake: the provincial cyberspace administration has five working days after receipt to check completeness. After receiving the submitted materials, the national authority has seven working days to decide whether to accept the application.
  • Security-assessment decision: the national authority's target is 45 working days after the written acceptance notice. It may extend the review for a complex case or when materials must be supplemented or corrected. An applicant may seek re-evaluation within 15 working days after receiving the result.
  • Security-assessment validity: a successful result is valid for three years from issuance. If the transfer must continue and no reapplication trigger has occurred, the processor may apply for a three-year extension within the 60-working-day period before expiry. Do not describe this as an automatic renewal.
  • Export certification validity: a personal information export certification certificate is valid for three years. To continue using certification after expiry, the processor must apply for certification again six months before the certificate expires. The certification body reports certificate issuance or a status change to the national certification platform within five working days.
  • Privacy-officer reporting: when a processor reaches the 1-million-person threshold, report the personal information protection officer's information to the competent municipal cyberspace administration within 30 working days. Report a material change within 30 working days after the change. The one-time 29 August 2025 deadline for processors already at the threshold has passed.
  • Incident response: PIPL requires immediate remediation when personal information has been or may have been leaked, altered, or lost, followed by notice to the protection authority and affected individuals unless the statutory exception for individual notice applies. PIPL does not give this duty a fixed number of hours.
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Primary sources

References and citations

PRC Personal Information Protection Law
cac.gov.cn4 citations
Referenced sections
  • Binding law for PIPL scope, cross-border conditions, periodic audits, impact assessments, three-year record retention, incident duties, and the 1 November 2021 effective date.
  • Article 74 sets the 1 November 2021 effective date.
  • Articles 54-56 require periodic compliance audits, pre-processing impact assessments for listed activities, and at least three years' retention of the assessment report and processing record.
Show 1 more
  • Article 57 requires immediate remediation and authority and individual notification for actual or possible leakage, alteration, or loss, subject to the stated exception for individual notice.
Provisions on Promoting and Regulating Cross-border Data Flow
cac.gov.cn4 citations
Referenced sections
  • Current cross-border exemptions, annual volume bands, assessment triggers, three-year result validity, extension process, and priority over inconsistent earlier measures.
  • Articles 3-9 and 13-14 establish current exemptions, thresholds, three-year assessment validity, priority over inconsistent earlier measures, and immediate effect on 22 March 2024.
  • Articles 5, 7 and 8 establish the calendar-year export thresholds, exemptions, assessment triggers, and standard-contract or certification band.
Show 1 more
  • Article 9 replaces the earlier two-year result period with three years and permits an extension application within 60 working days before expiry when no reapplication trigger has occurred.
Network Data Security Management Regulations
cac.gov.cn3 citations
Referenced sections
  • Personal-information and large-volume processor duties, annual large-platform reporting, and the 1 January 2025 effective date.
  • Articles 2, 21-28, 44 and 64 support scope, personal-information rules, large-volume duties, annual platform reporting, and the 1 January 2025 effective date.
  • Articles 44 and 62 define a large online platform and require its annual personal-information protection social responsibility report.
Personal Information Export Certification Measures
cac.gov.cn3 citations
Referenced sections
  • Current certification framework and 1 January 2026 effective date.
  • Establishes the certification route and its 1 January 2026 effective date.
  • Articles 8-9 set the three-year certificate term, the six-month pre-expiry application requirement, and the certification body's five-working-day certificate reporting duty.
Personal Information Protection Compliance Audit Measures
cac.gov.cn3 citations
Referenced sections
  • Current binding audit rules, including the two-year interval for processors at the stated volume threshold.
  • Articles 2-12 and 20 support audit scope, frequency, authority-directed audits, privacy-officer duties, and the 1 May 2025 effective date.
  • Article 4 requires an audit at least every two years for a processor above the stated volume threshold.
Small Personal Information Processor Personal Information Protection Simplified Measures
jswx.gov.cn3 citations
Referenced sections
  • Binding simplified compliance measures for small processors, effective 1 September 2026.
  • Official publication of Order No. 25, including the small-processor definition, simplified compliance measures, and 1 September 2026 effective date.
  • Binding measures effective 1 September 2026 that define small processors and establish the simplified audit interval and certification exception.
CAC Notice on Personal Information Protection Officer Reporting
cac.gov.cn2 citations
Referenced sections
  • Current officer-reporting threshold, 30-working-day event and change deadlines, and online filing route.
  • Sets the 1-million-person reporting threshold, the 30-working-day clocks for reaching the threshold and material changes, the online route, and the historical 29 August 2025 deadline.
CAC Personal Information Protection Policy Q&A, April 2026
cac.gov.cn2 citations
Referenced sections
  • Current official explanation of threshold counting, audit frequency, and minors' personal-information audits.
  • Explains how to count people for numerical thresholds and distinguishes the binding two-year audit interval for processors at the 10-million-person threshold from non-binding standards for smaller processors.
Measures for Security Assessment of Data Export
cac.gov.cn2 citations
Referenced sections
  • Application materials, authority review clocks, re-evaluation window, and change-based reapplication requirements, read with the later 2024 provisions.
  • Articles 7, 12-14 establish the five-day completeness check, seven-day acceptance decision, 45-working-day assessment target, extension possibility, 15-working-day re-evaluation window, and change-based reapplication rules.
Measures for the Standard Contract for Personal Information Export
cac.gov.cn2 citations
Referenced sections
  • Pre-export impact assessment, prescribed contract, 10-working-day filing deadline, filing materials, and change triggers.
  • Articles 5-8 establish the pre-export assessment and contract, 10-working-day filing deadline, filing materials, and change triggers.

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A PIPL entrusted-processing contract must define the purpose, duration, method, personal-information categories, safeguards, and both parties' duties. See the required terms and supporting records.

Is PIPL the same as GDPR?

No. China's PIPL and the EU GDPR overlap on core privacy controls, but differ in territorial scope, legal bases, roles, sensitive data, impact assessments, and transfer routes.

What counts as sensitive personal information in China?

PIPL uses a harm-based test for sensitive personal information and lists examples such as biometrics, health, financial accounts, location traces, and all personal information of children under 14.

What is separate consent under PIPL?

Separate consent under China's PIPL is a distinct consent for a specified processing activity. See when it applies, what notice must come first, and what evidence to keep.

What records should we keep for a PIPL impact assessment?

A PIPL impact-assessment file should preserve the Article 55 trigger, processing facts, Article 56 analysis, safeguards, decision, and processing record for at least three years.

What should an app collect as necessary personal information in China?

Use China's 2021 category rules to identify necessary information for an app's basic function. Keep that function available when users decline non-necessary data.

When can a company use the China standard contract route?

Use China's standard contract route only after applying the 2024 exemptions and confirming that no CAC security assessment is required. See current thresholds, filing steps, and change triggers.

When does a China PIPL security assessment apply?

A CAC data export security assessment applies to CIIO exports, important data, and specified high-volume personal-information exports after the 2024 exemptions are applied.